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July 19, 2017

OSHA Electronic Injury Reporting Set to Go Live August 1

Federal OSHA says it will launch its long-delayed electronic Injury Tracking Application (ITA) on August 1. The web-based reporting form will allow employers to electronically submit required injury and illness data from their completed 2016 OSHA Form 300A. We'll see what happens.

Last month, OSHA published a notice of proposed rulemaking to extend the deadline for submitting 2016 Form 300A to Dec. 1, 2017, to allow affected entities sufficient time to familiarize themselves with the electronic reporting system, and to provide the new administration an opportunity to review the new electronic reporting requirements prior to their implementation.

The data submission process will involve four steps:

Creating an establishment

Adding 300A summary data

Submitting data to OSHA

Reviewing the confirmation email.

The secure website will offer three options for data submission. One option will enable users to manually enter data into a web form. Another option will give users the ability to upload a CSV file to process single or multiple establishments at the same time. A third option will allow users of automated recordkeeping systems to transmit data electronically via an application programming interface.

Who is Impacted:

Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries with historically high rates of occupational injuries and illnesses.
What is Required:
Covered establishments with 250 or more employees must electronically submit information from OSHA Forms 300 (Log of Work-Related Injuries and Illnesses), 300A (Summary of Work-Related Injuries and Illnesses), and 301 (Injury and Illness Incident Report). Covered establishments with 20-249 employees must electronically submit information from OSHA Form 300A.

When to Submit Data:
This is a little fuzzy. Current proposed rulemaking extends the deadline for submitting 2016 Form 300A to Dec. 1, 2017. OSHA's original deadline was July 1, but the electronic submission interface wasn't available. The original rule also required information to be submitted by July 1 in 2018, by March 2 in 2019. These timelines are currently under review.